Public Comment: 156 (Briana Capra)

[ncx-gitbot]

Commenter Organization: Forest Carbon Works

Commenter: Briana Capra

2021 Deferred Harvest Methodology Section: Section 2 Additionality

Comment: The methodology does not specify a minimum harvest area for modeling the baseline scenario. The methodology acknowledges properties that may be as large as 2,000 hectares. Therefore the methodology encompasses both larger and smaller scale project activities. For smallscale activities, baseline harvesting may not be feasible because the harvest area is too small to be commercially viable. For large-scale activities, the baseline harvesting across such large areas in a single year may not be feasible. Therefore, the methodology fails to meet the requirement for the performance benchmark that requires these scales be assessed differently:The methodology encompasses both larger and smaller scale project activities and the performance (measured in terms of the performance benchmark metric) that may be practicability achieved in eachcase is substantially different

Proposed Change: VCS Rerefence: VCS Methodology Requirements Section 2.3.8

[ncx-gitbot]

NCX response: Many commenters raised questions about the assumptions within the baseline model regarding the relationship between property size (< 355 acres, >10000 acres) and acreage likely to be harvested in a given year. We have clarified the assumptions and framework of the baseline modeling process that specify this relationship.